[WISPA] FCC FNPRM on Universal Service contributions -- ISPs could be taxed
Over the past few years, the FCC has been redesigning its Universal Service Fund. In last fall's CAF Order, new rules for dispersing the fund were laid out. We've discussed that a bit here. Last week, the FCC adopted a new Further Notice of Proposed Rulemaking, this time on how the funds for USF will be collected. At present, providers of interstate telecommunications are taxed; the current rate is 17.3%. It's so high, in part, because the contribution base (mostly long distance calling) keeps shrinking. ISPs are not taxed. But the new Notice opens up all sorts of ways to broaden the tax base. And among those ideas, ISPs could be taxed. That's not the sole idea being put on the table, but when they declared DSL to be non-common carriage and removed it from the USF rolls, the tax rate on what was left went up significantly. So they may want to put it back on the rolls, but not in a way that hurts ILECs' (their patrons') competitive positioning. The Notice is 182 pages long and I haven't read it all yet, and I doubt too many will want to bother. But I do suggest paying attention to this one, so the WISP industry's interests are not hurt. The full notice is here: http://transition.fcc.gov/Daily_Releases/Daily_Business/2012/db0430/FCC-12-46A1.pdf -- Fred R. Goldstein fred at interisle.net Interisle Consulting Group +1 617 795 2701 ___ Wireless mailing list Wireless@wispa.org http://lists.wispa.org/mailman/listinfo/wireless
[WISPA] Low-cost CLEC market entry approach for unsubsidized competitor
The current FCC rules per November's CAF order allow ILECs to be subsidized to provide broadband unless there is an unsubsidized competitor who provides both voice and data service. Jack Unger has written an excellent petition to the FCC to change that to allow it to be unsubsidized competition, wherein the data provider needn't be the voice provider. But there's no guarantee that the FCC (currently down to three seated Commissioners) will take such action. A WISP can provide the needed voice service via VoIP. It need not be a certificated CLEC. However, to get the VoIP service and local numbers, it still needs a CLEC with a connection to (at minimum) the tandem switch serving its area. In some rural areas, this might not be available. So the WISP might need to create a CLEC, or at least get one to serve its area. While the traditional approach to starting a CLEC requires a switch, that rather costly item, which a lot of ISPs don't want to have to manage, can be finessed by using a remote gateway. At least one CLEC I'm working with offers a remote rent a call agent service, where there Class 4/5 call agent, which is equipped with Signaling System 7 (a big expense), can serve gateways anywhere, passing signaling (H.248) across the Internet or, ideally, a VPN. So the rural CLEC just has a media gateway and SBC, and orders trunks into the local central office. The VoIP side of the gateway then feeds the subscribers. I'm trying to assess whether it's worth anyone's pursuing to set this up as an offering for WISPs. Does anyone see a market for this type of service? Would it help anyone meet the unsubsidized competitor requirement? Thanks... -- Fred Goldsteink1io fgoldstein at ionary.com ionary Consulting http://www.ionary.com/ +1 617 795 2701 WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
[WISPA] 3650 MHz permission letters?
Does anyone have a standard letter to use to ask permission from satellite earth stations to use the 3650 MHz band within the 150 mile exclusion zone? Thanks. -- Fred Goldsteink1io fgoldstein at ionary.com ionary Consulting http://www.ionary.com/ +1 617 795 2701 WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
[WISPA] My report on FCC Order and FNPRM, ICC and USF
At its October meeting, the FCC adopted an Order and Further Notice of Proposed Rulemaking in a series of long-open dockets. These cover related topics including the Universal Service Fund, Intercarrier Compensation and VoIP. But the Order itself wasn't released until the Friday before Thanksgiving. And what a document it is! It's 751 dense pages long. I've spent a lot of time since then reading through it, taking notes, and writing up a report on its contents. My writeup turned out to be over 10,000 words long, 18 pages. There's a lot to cover! Now a lot of people might think that these topics are arcane and of no interest to them, but as it turns out, there's more to it than was mentioned in the FCC's feel-good press releases. They take great liberty with these topics, especially in their proposals in the Further NPRM. While the Order is somewhat surprising for how little it has actually settled after all these years, compared to what's left, the questions they ask go way beyond their original scope. They even reach into the core of the Internet itself, asking if they should regulate the peering and interconnection arrangements of the Internet backbone, relevant on the rather specious grounds that like VoIP telephony, it uses IP, and even carries some phone calls. Here's why it might be worth slogging through my report, which after all is only a fraction of the size of the Order itself: WISPs need to be aware of the Order on USF because in restructuring the High Cost Fund into the Connect America Fund, they will subsidize Incumbent LECs to provide broadband Internet access (the information service, not wholesale access that ISPs can lease) to currently-unserved homes and businesses. This is especially critical to rural WISPs. If an area is not marked as unserved on the National Broadband Map, or if an existing unsubsidized broadband provider (cable, WISP, etc.) is already there, then the ILEC can't get subsidized. In some cases, however, WISP competitors may bid to become the subsidized provider in remote areas. Intercarrier Compensation (ICC) sounds arcane, but it provides an excuse to regulate many aspects of VoIP and other advanced services. It can be used as a competitive weapon against competitive providers. It's an important part of many CLECs' revenue stream, and impacts the competitive balance of the industry. The new Order is far from complete; a lot of issues are left to the FNPRM. So the real winners and losers haven't been picked yet. VoIP is presented as an ICC issue, but in this proceeding, it's a lot more. The FCC has finally ruled on how Vonage-type services should be treated for compensation purposes. But it's clear from their Order and especially the questions in the FNPRM that the FCC is almost utterly clueless about how VoIP actually works, especially the non-Vonage kinds, and for that matter how the Internet works. These are telephone-network lawyers trying to impose their ideology atop the Internet. And so they're opening up the option of using this proceeding as an excuse to regulate the Internet itself, to treat ISPs as common carriers. This is a Danger Will Robinson moment! Read the latter part of my report to see some of the details, and then you might want to pull down the actual FCC document to see what I'm talking about. It's scary in many ways. I have participated in these proceedings since they began, filing several Comments along the way. In 2008, I organized a group of about 10 client CLECs, the Coalition for Rational Universal Service and Intercarrier Reform (CRUSIR), to make group Comments. I am assembling interest for further Comments. In the meantime, my report is here: http://www.ionary.com/FCC-CAF-and-ICC-Order-analysis.pdf Feel free to pass this on to your colleagues. Your ideas and feedback are welcome. -- Fred Goldsteink1io fgoldstein at ionary.com ionary Consulting http://www.ionary.com/ +1 617 795 2701 WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
[WISPA] FCC releases USF/ICC Order, rules on subsidizing ILECs
On Friday, the FCC finally released the Order in their Intercarrier Compensation and Universal Service Fund docket. The executive summary had come out with the Adoption at last month's FCC Public Meeting, but the 759-page (!) Order took a while to finish. The results, from a WISP perspective, are not nearly as bad as could have been. The FCC has taken safeguards to make it easier for an unsubsidized WISP to prevent subsidized competition from an incumbent LEC. The high-cost portions of the Universal Service Fund are being restructured into the Connect America Fund. This will come into being in three phases, each with different rules for Price Cap Carriers and Rate of Return Carriers. About 95% of phone lines are in the former category; the latter are basically small rural carriers who depend upon USF. Phase I is just 2012. Price Cap Carriers will be offered $775 per line to add 4/1 broadband serivce to unserved areas that they weren't otherwise going to serve. They can choose how many lines this applies to. If the location is served on the National Broadband Map, or if the ILEC *knows* it's served by an unsubsidized competitor, it's off limits. I think this must be at least 768k fixed service. So this might be a good time to make sure the mappers are aware of your service areas, or to think about short-term service expansion. The date by which you must be on the map isn't set yet, but it's presumably in 1H2012. Phase II starts in 2013. For this, Price Cap Carriers will be offered support based on a cost model that the FCC will create in 2012. Once the model is complete, the ILEC will decide if it wants to take that support for its territory on a state-by-state (all of a state or nothing) basis. Again, only unserved areas will get support, though an ILEC can use support to build common plant in an area that is more than 50% unserved. So a new DSLAM that covers 40% unserved would not be covered, but ont that covers 60% unserved would be. So again it's important for WISPs to make their presence known. If the ILEC turns down the state, USF support goes to the low bidder. Phase III starts in 2018, and will be entirely bid-based, but the details will be worked out in the future. A separate Extremely High Cost fund will allocate up to $100M/year for locations too costly (by the model) to serve via the standard subsidy. This will be separately bid, and it's assumed that fixed wireless and satellite will be the mostly likely technologies. So this could allow some subsidies to rustic-but-Bell-area WISPs. The FCC notes that while this gives ILECs first dibs on funding, it also takes away Price Cap Carrier USF from areas served by unsubsidized competitors, so WISPs could theoretically come out better under the new rules. Now here's a catch: Unsubsidized competitor is defined as a provider of both voice and broadband service. It's not entirely obvious (you try parsing 759 pages of FCC-speak this quickly... ;-) ) if that applies to the Price Cap Carrier model, or just the rural Rate of Return case, since the PCCs already offer unsubsidized voice across most of their territories, and the map isn't about voice. In the rural Rate of Return Carrier case, voice will be more important. This does not mean that the WISP must be a CLEC per se; it might be high-quality (QoS) VoIP offered in conjunction with a CLEC who has local numbers, for instance. But for some ISPs, this might be a good time to start thinking about adding voice service. (My talk at FISPA last month was about the case for whether an ISP should start up a CLEC.) In areas served by rate-of-return carriers, the new rules phase out (over 3 years) all USF support to an ILEC that is 100% overlapped (voice and broadband) by an unsubsidized carrier, typically cable. If there is less than 100% overlap, then support will be reduced, but the actual methodology is left to be determined via the Further NPRM. So on balance, the FCC has done a lot less harm to the rural WISP community than it could have, while still encouraging ILECs to deploy more broadband via subsidies. -- Fred Goldsteink1io fgoldstein at ionary.com ionary Consulting http://www.ionary.com/ +1 617 795 2701 WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
[WISPA] FCC's proposed Remote Areas Fund
I've been following the FCC's Intercarrier Compensation and Universal Service dockets for over a decade now, and have filed a heap of Comments on them. So naturally when an Order comes out, I pay a lot of attention. Usually I send a memo about it to my clients. However, while the FCC adopted an Order last Thursday, they haven't released the Order itself yet! This isn't unprecedented, but is unusual. In 2003, they adopted the Triennial Review Order in February and only finished the text in August. The adoption of the order was fake, to meet a deadline; they fought over it for months. Then it was remanded, and they fought over it some more. I hope this one doesn't take so long. Rumor is that it's about done, so I don't know why it isn't out yet. They did release an Executive Summary, which basically leaves a lot of details to the actual Order. But this one paragraph struck me as interesting to WISPs: 14. Remote Areas Fund. We allocate at least $100 million per year to ensure that Americans living in the most remote areas in the nation, where the cost of deploying traditional terrestrial broadband networks is extremely high, can obtain affordable access through alternative technology platforms, including satellite and unlicensed wireless services.3 We propose in the FNPRM a structure and operational details for that mechanism, including the form of support, eligible geographic areas and providers, and public interest obligations. We expect to finalize the Remote Areas Fund in 2012 with implementation in 2013. The FNPRM means further rulemaking is being opened for Comment; it's not decided yet. Since they're talking about unlicensed wireless, WISPs might be able to play. They will however have to become Eligible. Wireline LECs usually get their ETC status from states, while wireless carriers can get it from the FCC. It's not clear how hard it will be for WISPs to get ETC status. It's not a big fund, and it only applies to really remote areas, but it might be useful for some of this group. So let's see what is in the Order. -- Fred Goldsteink1io fgoldstein at ionary.com ionary Consulting http://www.ionary.com/ +1 617 795 2701 WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
[WISPA] Over-water shots
What kind of experience does anyone here have in shooting backhaul links over water? I know that it does all sorts of nasty things to microwave propagation, but I have a large group of lakeside access points that will depend on backhaul being delivered from across the lake, about 10-15 miles. For the most part we're high enough so that the surface of the water is beyond the second fresnel zone, often beyond the third. This is at 5.8 GHz. Specifically, Should I expect that ducting and other lake effects will knock them all out at once, or will it help a lot that the lake shore units mesh with each other? Will having two backhaul antennas on the tower five feet vertically separated help, or will both paths usually go out at once? (I'm thinking that some weird reflection issues will hit different heights at different times.) Horizontal polarization is said to work better over water. So is it crazy to try a dual-polarization MIMO link? Thanks. -- Fred Goldsteink1io fgoldstein at ionary.com ionary Consulting http://www.ionary.com/ +1 617 795 2701 WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
[WISPA] Slight variations in antenna height, big path loss change
I'm doing some path loss estimates in RadioMobile. Mainly 5.8 GHz stuff. I have a place where I'd like to run a point-to-multipoint sector as an injection feed to multiple APs in the mesh. This would need to run AirMax or Nstreme or NV2 in order to manage the traffic, but that part seems easy enough. If I don't use NV2 and claim the SkyPilot rule, then my ERP is capped at +36 dBm. (So I'm kind of marginal on path loss already.) I can use a 20 dB sector antenna (AM2-60), whose footprint covers all of the APs I'd like to reach, up to 22 kilometers away. The APs are set to have 24 dB panel antennas. So they can run point to point ERP upstream, to the extent that it helps the fade margin in that direction. BTW the paths are mostly over water, but elevated by more than 2-3 Fresnel zones. Now here's the weird part. In RadioMobile, when I adjust the PtMP end's height in half-meter increments, path loss jumps all over the place. To one destination 18.5 km away: At 7 meters, 134.5 dB. At 7.5 meters, 144.7 dB. At 8 meters, 139.3 dB. At 8.5 meters, 134.4 dB. At 10 meters, 137.0 dB. Now to a different destination only 12.5 km away (the closest one), I get: At 7 meters, 137.4 dB. At 7.5 meters, 150.7 dB. At 8 meters, 132.2 dB. At 8.5 meters, 131.7 dB. At 10 meters, 136.5 dB. Well, the obvious answer so far might be to avoid the 7.5 meter height, but now going to a third destination 16.8 kilometers away, I get: At 7 meters, 141.6 dB. At 7.5 meters, 134.3 dB. At 8 meters, 136.6 dB. At 8.5 meters, 139.5 dB. At 10 meters, 151.9 dB. So there's no height that makes everyone happy, and that assumes I actually get a choice of height. Most likely it goes on the power pole wherever they let us attach it. And tweaking the remote ends doesn't make that much difference at all. So here's the question. Is this type of variation likely to exist in the real world, or is this just RadioMobile's propagation model being overly sensitive? Thanks! -- Fred Goldsteink1io fgoldstein at ionary.com ionary Consulting http://www.ionary.com/ +1 617 795 2701 WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
[WISPA] Multiple sectors, one frequency?
If I have a site with, say, Ubiquiti Rocket M5 radios plugged into 120 degree sector antennas, with Airmax (TDMA) turned on, do they have to be on separate frequencies, or can they coexist on one? The 5.8 GHz band is kind of crowded to be having three access frequencies plus two or more backhaul frequencies... thanks. -- Fred Goldsteink1io fgoldstein at ionary.com ionary Consulting http://www.ionary.com/ +1 617 795 2701 WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
[WISPA] MIMO 5.8 GHz panel antennas?
I wonder if any of you have experience with 5.8 GHz MIMO antennas. I'm trying to design a point-to-point link, about 10 miles, that will carry a high percentage of a whole network's backhaul. So I'd like it to go at about 80 Mbps, MCS 12 in 20 MHz. The UBNT SR71-15 card can plug into a Routerboard and thus feed two antennas, or a dual-polarized antenna. I'd rather have one antenna than two. I can find dual-feed 2' dishes, but they're on the large side, with wind load and visibility issues. And I see a lot of single-feed panels, which can handle 11a-type traffic. I can run Ethernet into an external radio that comes in a panel, but that adds a hop and more complexity, and frankly most of the specs don't match the SR71-15's. There will be at least three antennas at each end, possibly four (backhaul plus local access). MiniPCI radios in, say, an RB600 seem easier to deal with. But who makes a standalone 5.8 GHz dual-polarized panel, something the 22-25 dB range (13-16)? UBNT makes MIMO sector antennas, and makes panels with built-in radios, but it doesn't seem to have a PTP panel antenna to mate with the SR71-15. ARC has one that works with its built-in enclosure system; do I just leave the enclosure empty and route the cables through it? (Seems hokey.) RADwin has one designed for its own system; I don't know how well it would work otherwise and it's way expensive. Suggestions? Thanks! -- Fred Goldsteink1io fgoldstein at ionary.com ionary Consulting http://www.ionary.com/ +1 617 795 2701 WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
[WISPA] Pole-mounted base stations
A design I'm working on is in a hilly wooded rural/resort area, not farmland. It will need a fair number (perhaps a few dozen) sites to cover the planned turf. Each node will need both backhaul (mesh, in the loose sense) and access antennas. The obvious place to put these is atop utility poles. I think the local electric cooperative will cooperate and let us rent pole space. We may however need to put additional poles in some places. They seem cheaper than metal towers and are less likely to raise the locals' eyebrows. Does anyone out there have experience with this sort of arrangement? We're in the budgeting stage now. I have an idea what the radios cost but the installation might be the bigger deal. The big engineering firms are more used to fancy cellular and fiber installs, not WISP-style radios. So we may also want to bring in someone with this kind of WISP experience to do some consulting or setup with us too. Thanks. -- Fred Goldsteink1io fgoldstein at ionary.com ionary Consulting http://www.ionary.com/ +1 617 795 2701 WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
[WISPA] Maximum sector power?
I'm just a little confused about some of these nice-looking access points. The UBNT Rocket M5, for instance, can put out +27 dBm. It plugs *right into* a nice 19dB sector antenna. Okay, the smaller, 120 dB sector is only 16 dB. Now math is not really my thing but I get a total ERP there of +43 to 46 dBm. FCC Rule 15.247 states that the maximum transmitted power output for digitally-modulated intentional radiators in the 5725-5850 MHz band (ISM) is 1 watt, and the maximum antenna gain is 6 dBi. Each additional dB of antanna gain means one less dB of power. So the maximum ERP is 4 watts (+36). Point-to-point is an exception in that specific band; it is allowed unlimited antenna gain. But point-to-multipoint systems, omnidirectional applications, and multiple co-located intentional radiators transmitting the same information are under the cap. So am I correct in assuming that everybody who uses the Rocket M5, or any other similar PtMP system for subscriber access, turns the transmitter power REAL low (~+20 + feedline loss), in order to keep the ERP below +36? Or are we assuming that since you're technically only transmitting and receiving to one end user at a time, it's really PtP? SkyPilot's legal hack, of course, is to have eight 45 degree sector antennas and only use one at a time, so it is legally PTP even with +42 EiRP. And with advanced 11N 4x4 beamforming antennas, something like that will become relatively easy. But we're not quite there yet. Thoughts? -- Fred Goldsteink1io fgoldstein at ionary.com ionary Consulting http://www.ionary.com/ +1 617 795 2701 WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
[WISPA] MicroTik HWMPplus mesh?
First off, I'd like to say hello to the list. Mike Hammett pointed me at it a couple of weeks ago, after I posted a wireless-related question (wireless in the trees) at isp-clec, and he reposted it here. This list is a lot more active... I've been reading the past few months archives and it's really quite informative. I'm a consultant working with competitive service providers all over the place. I don't run a WISP but some clients do. I am working now with a startup that wants to serve some unserved (no cable or DSL, just long-loop POTS/dial-up) remote territory which is about to get middle mile service to the nearest city (year-round pop. 10,000, but it's big for the area) thanks to a stimulus grant. The unserved last mile area covers a strip about 5 to 30 miles from the backbone point. It's the RF environment from hell: Heavily wooded and hilly. The most valuable strip of land is a long narrow beachfront strip a block or so wide, with a palisade (steep wooded hill) blocking it from the rest of the area. Plus it's convex (curves out into the big lake) so your line of sight within the beachside strip is very small. So in most places on the waterfront there's not even cellular service, since the cell sites are over the rim. No WISP is crazy enough to go there. My clients and I, however, are unusually crazy... why else would we be in the communications business? Given that environment, there only way to get to most of the subscribers is via multiple hops. We'd come down to the beach in at least two points near the ends, maybe in the middle too, and build microwave rings. I don't see how this could work with any of the canned mesh solutions. Most, like SkyPilot, only mesh at 5.8 Ghz, and there are some paths that are just too woody for that to work. Some of the subscriber access sites may need 900 too. I think each RF path and local-coverage cell will have to be engineered to local conditions. What looks to be the most flexible approach might be to use the MicroTik Routerboard multi-radio mPCI systems. Then we can use off-the-shelf 5.8 GHz cards and PtP antennas for the clear paths, and plug in the Ubiquiti XR9 or similar high-power 900 radio for tree blasting. User access would probably be sectorized at whatever band works. MicroTik says they have a meshing protocol, HWMPplus, that provides Layer 2 (this is critical; we're not building a Layer 3 network, and with this many hops, latency and loss are critical) dynamic meshing, essentially applying a routing protocol (smarter than bridge STPs) among nodes. I can't find any documentation for it on line, though, and a distributor I've been talking to has never tried or sold it. So does anyone on the list have any experience with the HWMPplus mesh? Or any other suggestions? Thanks! -- Fred Goldsteink1io fgoldstein at ionary.com ionary Consulting http://www.ionary.com/ +1 617 795 2701 WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
